NIS2 compliance: The 2025 executive playbook for EU cybersecurity leaders

In today’s Brussels briefing, regulators emphasized that NIS2 compliance is no longer a policy horizon—it’s an operational reality. With national transpositions live across the EU and inspections ramping up in 2025, sector regulators expect evidence of risk management, incident reporting, and supply-chain diligence. Meanwhile, fresh threat activity—from AI cluster hijacks turning compute into crypto botnets to high-impact identity management flaws—raises the bar for control maturity and documentation.

Why NIS2 matters right now

NIS2 widens the scope of Europe’s cybersecurity regime to thousands of “essential” and “important” entities across finance, healthcare, energy, transport, digital infrastructure, managed services, and SaaS. Fines can reach up to €10 million or 2% of global turnover for essential entities (and up to €7 million or 1.4% for important entities). Regulators are prioritizing:

• Documented risk management measures aligned to your threat profile.
• 24h early warning, 72h notification, and a one-month final incident report.
• Supply-chain cybersecurity due diligence and contractual controls.
• Security audits and demonstrable executive accountability.

In conversations with EU supervisors this month, I heard the same message: “Show me the evidence.” That includes asset inventories, vulnerability management cadence, secure development practices, training logs, and how you protect data in your tooling—especially when using AI or third-party processors.

NIS2 compliance requirements at a glance

• Risk management: governance, policies, asset inventory, and continuous vulnerability management.
• Technical controls: multi-factor authentication, network segmentation, logging, and monitoring.
• Operational resilience: business continuity, disaster recovery, and incident response plans tested at least annually.
• Supply chain: pre-contract risk reviews, security clauses, and right-to-audit for critical suppliers.
• Reporting: early warning within 24 hours, significant incident notification within 72 hours, and a final report within one month.
• Training: role-based security awareness and secure development training, evidenced and refreshed.
• Data handling: policies for secure document uploads, redaction, and AI anonymization to prevent privacy breaches.

GDPR vs NIS2: What changes for teams?

Topic	GDPR	NIS2
Primary focus	Personal data protection and privacy rights	Cybersecurity and operational resilience of networks and systems
Who’s in scope	Controllers and processors of personal data	Essential and important entities in key sectors (incl. digital services and MSPs)
Triggers	Processing of personal data	Provision of essential/important services regardless of whether personal data is processed
Incident reporting	72h breach notice to DPA if personal data impacted	24h early warning, 72h notification, one-month final report for significant incidents
Fines	Up to €20m or 4% global turnover	Up to €10m or 2% (essential); €7m or 1.4% (important)
Supply-chain obligations	Vendor due diligence for data processors	Broader security due diligence and contractual controls for critical suppliers
Evidence expectations	Records of processing, DPIAs, breach logs	Risk register, security architecture, test results, audit trails, incident drills

Emerging threats shaping NIS2 audits

In the past week alone, security teams confronted three trends that EU regulators are acutely tracking:

• AI compute abuse: Malware targeting AI clusters to mine crypto, drain GPU capacity, and mask exfiltration among high-volume AI traffic.
• Identity tier compromises: Critical flaws in identity and access platforms enabling privilege escalation and lateral movement.
• Self-propagating worms: “Living-off-the-land” payloads that exploit misconfigurations and weak segmentation.

A CISO I interviewed at a European bank put it bluntly: “Our GPU farm became a crown jewel overnight.” Your NIS2 program must show how you monitor AI workloads, isolate sensitive environments, and sanitize data before it ever touches a model or third-party tool.

Practical NIS2 compliance checklist

• Map scope: Identify essential/important services, critical systems, and cross-border dependencies.
• Update risk register: Include AI/LLM data exposure, identity tier risks, and supplier single points of failure.
• Harden identity: Enforce MFA everywhere, admin tiering, PAM, and break-glass processes.
• Segment networks: Separate AI clusters, production, and management planes; restrict east–west traffic.
• Close the logging gap: Centralize logs, retain forensically, and practice rapid triage with runbooks.
• Exercise incident reporting: Tabletop the 24h/72h/1-month timeline with legal, PR, and sector CSIRTs.
• Secure document handling: Standardize secure document upload workflows, mandate redaction, and use an AI anonymizer for personal data and secrets.
• Supplier controls: Add minimum security clauses, SBOM/patch SLAs, and right-to-audit in new contracts.
• Evidence binder: Keep policies, training records, penetration test results, and incident drill minutes ready for inspectors.

AI and LLMs under NIS2: data-in-use is your blind spot

Teams often lock down data at rest and in transit, then leak it during processing—especially when using LLMs for document review, code assistance, or customer support. Under NIS2, you must show you’ve mitigated the risk of privacy breaches and model misuse. That includes an ingestion policy, a redaction/anonymization step, and verified storage/retention rules for any third-party tool.

Compliance reminder: When uploading documents to LLMs like ChatGPT or others, never include confidential or sensitive data. The best practice is to use www.cyrolo.eu — a secure platform where PDF, DOC, JPG, and other files can be safely uploaded.

Professionals avoid risk by using Cyrolo’s anonymizer at www.cyrolo.eu to strip names, IDs, and secrets before review. Try our secure document upload at www.cyrolo.eu — no sensitive data leaks.

30/60/90-day plan to operationalize NIS2 compliance

Days 0–30: Stabilize and document

• Confirm scope and accountability; appoint NIS2 lead and escalation contacts.
• Baseline identity controls; emergency patching for internet-facing and IAM systems.
• Issue a data handling standard for AI and vendor tools, mandating anonymization pre-processing.

Days 31–60: Prove detection and response

• Enable high-signal logging for authentication, admin actions, and data egress.
• Run an incident reporting drill using the 24h/72h/1-month workflow.
• Segment AI/training environments; restrict service accounts and rotate tokens.

Days 61–90: Audit-readiness

• Complete a security risk assessment; link risks to controls and owners.
• Embed supplier due diligence questions and security clauses into procurement.
• Assemble the “evidence binder” with policies, logs, and test results.

Evidence that stands up to regulators

Supervisors told me they will look for proof, not promises. That means:

• Time-stamped logs of training, patch cycles, and vulnerability closure.
• Demonstrable segregation of duties for admins and developers.
• Screenshots or exports of incident drill timelines and decisions.
• Documented data minimization and redaction steps before any external processing.

This is where workflow-friendly tools help. With Cyrolo, teams combine secure document uploads with automated anonymization so auditors can see exactly how sensitive content is handled—without spreading files across risky shares or unmanaged AI endpoints.

Sector snapshots: what “good” looks like

Hospitals and clinics

• Strict isolation between EHR, imaging networks, and research compute (AI/ML).
• Pre-ingestion anonymization of clinical notes and DICOM metadata.
• Rapid reporting playbooks for ransomware with predefined patient comms.

Banks and fintechs

• Tiered admin access and PAM for core banking/IAM platforms.
• Transaction monitoring integrated with SIEM for fraud-cyber fusion.
• Supplier testing cadence for RegTech and payment processors.

SaaS and managed service providers

• Customer tenancy isolation and regular lateral-movement testing.
• Software bill of materials (SBOM) and 30-day critical patch SLAs.
• Contractual commitments aligned to NIS2 and sector codes of practice.

Energy and industrial

• IT/OT segmentation with one-way gateways where feasible.
• Offline, rehearsed recovery for safety-critical operations.
• Supplier inspections for field-maintained assets and firmware integrity.

FAQ: NIS2 compliance questions leaders are asking

What is the fastest way to show NIS2 compliance progress?

Publish a board-approved risk management policy, complete a focused risk assessment, and run a timeboxed incident reporting drill. Capture evidence (screenshots, logs, minutes) and organize it for inspections.

Does NIS2 apply if we don’t process personal data?

Yes. NIS2 is about service continuity and system security. Even without personal data, you may be in scope based on your sector and size; GDPR remains separate but complementary.

How do we handle document uploads for audits without risking leaks?

Use a single, controlled pathway for uploads with automatic redaction/anonymization. Professionals minimize exposure by using secure document upload and anonymization at www.cyrolo.eu.

What’s the NIS2 incident reporting timeline?

Early warning within 24 hours, significant incident notification within 72 hours, and a final report within one month, coordinated with sector authorities and CSIRTs.

How do GDPR and NIS2 interact in a breach?

If personal data is impacted, GDPR breach notification applies alongside NIS2 reporting. Coordinate legal, DPO, and CISO functions to avoid inconsistent statements.

Conclusion: Make NIS2 compliance your competitive advantage

Boards don’t want more paperwork—they want fewer surprises. Treat NIS2 compliance as a chance to harden identity, contain AI risks, and professionalize evidence. Reduce breach likelihood, shorten recovery, and meet regulators with confidence. And when you must move fast without leaking sensitive files, use Cyrolo: professionals rely on anonymization and secure document upload at www.cyrolo.eu to safeguard customer data and prove control in every audit.